Text For Citation: 01 Item/Group: 017 Hazard:

29 CFR 1910.119(d)(3)(i)(B): Process Safety Information. Information pertaining to the equipment in the process shall include: Piping and instrument diagrams (P&ID's): a. Chlorination process safety information (PSI) was not accurate in that the chlorine knockout pot (T-598-04) removed in 2012 was still located on P&IDs. Additionally, the knockout pot had been located on both P&ID 4-PID-202-6 and 4-PID-203-6, with three different designations (T-420-04, T-598-04 and T-587-04). b. PSI for the chlorination 40R reactor process was not accurate in that the piping and instrument diagram (P&ID) identification or page number provided, 16-95-1, was from a format that was no longer used by the employer, and could not be used to cross reference an active P&ID to the process equipment or relief device. Additionally this P&ID was not part of the PSI file. c. PSI for the phosphites 72R reactor process was incorrect. P&IDs compiled in the PSI package/binder were not for the 72R process, but showed the 34R reactor instead of the 72R reactor. d. PSI for the 36R reactor was inaccurate. P&ID 23-PID-056-27: the xylene feed was not shown for the 36R reactor. Additionally equipment data, such as pump flow rates and pressure and vessel capacities were not listed. e. PSI for the 36R reactor was inaccurate. P& ID 23-PID-084-27: the xylene feed was not shown for the 32R reactor. f. P&ID 10-PID-008-35 was not accurate in that it showed equipment that was removed from service (a PCP storage tank) and did not list data for equipment, such as relief device pressure settings and tank capacities. g. P&ID 22-PID-302-27 was not accurate in that it showed equipment that was removed from service (a PCl3 storage tank.) h. P&ID 1-PID-176-17 was not accurate in that it did not indicate where chlorine feed lines went, where the feed lines linked to another P&ID, and did not show equipment that had been removed from service (X-076-1 Ultraviolet.) i. P&ID 23-PID-082-27 was not accurate in that dual valves were missing for flow into the R-034-23 reactor (one each for DP10 flow, catalyst and alcohol flow) and the DP10 flow meter was missing. j. P&ID 4-PID-202-6 was not accurate in that it showed equipment (a knockout pot) that was removed and replaced with piping circuitry. 29 CFR 1910.119(e)(3)(vi): Process hazard analysis. The process hazard analysis shall address: Human factors: a. Phosphites and chlorination PHA: the team(s) did not address the human factor of shift changeover. The employer had not addressed this appropriately in the PHA or by implementing a formal shift change procedure for informational exchange. b. Phosphites and chlorination PHA: the team(s) did not address off shift supervisory availability and the lack of formal maintenance work order use for repair on off shifts.